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KSeF and the accounting of a company expense by an employee

Mandatory from 1st July 2024 for most taxpayers, KSeF is a revolutionary change that will affect not only the issuing and sending of sales invoices and the receipt of purchase invoices related to the taxpayer’s business, but also other, seemingly less important, processes in every company, without which, however, it cannot function. One of these is employee purchases, including, for example, fuel at petrol stations or office supplies and small groceries at supermarkets.

What it currently looks like?

It is standard practice for companies to make some of their day-to-day purchases directly by their employees, who receive either a paper invoice directly to their hand or an electronic invoice by e-mail, usually in pdf format. After the invoice has been accurately described according to the guidelines of the accounting department, it is then forwarded to the accounting department.

The accounting department checks the formal correctness of the document, the description and, after the expense has been approved, sometimes also by the employee’s superior, the invoice is posted and the employee, if he or she has paid with his or her own funds, is reimbursed the money assumed. The whole process of accounting for a business expense is usually a number of steps and described in an internal company procedure available on the company’s intranet.

How will KSeF affect the accounting of purchases made by employees?

From 1st July 2024, an employee will no longer receive an invoice in his or her hand or email inbox for purchases made. Or at least, he or she will not receive the invoice in legal meaning, because this will only be possible via KSeF. In the B2B circuit, all invoices will be sent and received via KSeF, and will be identifiable by the recipient thanks to the unique identification number assigned to it.

On the other hand, the KSeF system will only be accessed by persons authorised by the taxpayer, as a rule employees of the accounting department, so their transfer will take place without the involvement of the person who actually made the purchase.

Another problem is that it is not possible to sort invoices in KSeF. All purchase invoices, regardless of who issued them and what they relate to, will flow into one collection. Thus, an invoice relating to a purchase made by an employee will appear in the list of invoices among many others (sometimes even thousands) issued by other suppliers of the entity, without being easily searchable.

It should also be noted that only structured invoices, i.e. those drawn up in accordance with a standardised template with compulsory, additional and optional fields, will be sent via KSeF, so the issuing entity will have limited possibilities for modifying the content. Furthermore, they will not be able to add to the invoice any attachments.

How to prepare for changes in the purchasing process?

In many ways, KSeF will streamline the invoicing process and be a tool that offers real time savings for businesses. However, there is no denying that purchasing by employees will be significantly hampered, which is why proper preparation is so important.

  • Firstly, an overall assessment of the company’s preparedness for the implementation of KSeF should be made. We write more extensively on this topic in our blog post: KSeF – assessment of preparedness for the new duty.
  • Secondly, carefully analyse the current employee purchasing process and, if it has been formalised in the form of a procedure, that procedure as well, so as to determine how it should be adapted to the changes introduced by KSeF.
  • Thirdly, ensure that our accounting and finance system allows us to link to KSeF in such a way that invoices from individual suppliers are sorted, e.g. by NIP number.
  • Fourthly, in the case of regular contractors from whom we make small purchases, e.g. a single brand petrol station or a nearby supermarket chain, it is worth reviewing how they will approach the new KSeF obligations and whether they will offer solutions that address our concerns.
  • Fifthly, consider that, for the first months after the introduction of the mandatory KSeF, employees who will be purchasing for us should ask suppliers to (1) send the visualisation of invoices to an email address in parallel or hand over a hard copy (this solution will be possible, but it should be remembered that the visualisation will not be an invoice) and (2) attach attachments to the visualisation, if necessary, or include in the „optional” field a link to a virtual drive where downloads will be placed. It is also worth to put into practise the above solutions before 1 July 2024 so as not to be caught by surprise. As of that date, invoicing outside KSeF will no longer be possible for most entities in B2B relationships.

Of course, it is to be expected that invoice issuers will try to introduce facilities for their customers accustomed to the current standards, i.e. receiving an invoice ‘on the spot’, in the form of, for example, printing out or sending a visualisation of the invoice – provided, however, that KSeF itself allows such a quick action. This does not, however, relieve the recipient of the invoice of the need to identify such an invoice in KSeF and book it correctly, although this will probably be helpful.